BSA/AML Student Exercises Dec. 2022

• Customer Identification: Bank personnel should first refer to the Bank's CIP requirements. At a minimum, the Bank must obtain the following information to validate the true identity of an individual or entity seeking to open an account: o Name o For individuals, date of birth o Address:  Individual — residential or business street address  Individual who does not have a residential or business street address — an Army Post Office or Fleet Post Office box number, or the residential or business street address of next of kin or another contact individual o Entity - For persons other than individuals, (i.e., corporations, partnerships, and trusts) principal place of business and, if different, mailing address. o Identification Number:  U.S. Person - a U.S. taxpayer identification number (i.e.., social security number, individual taxpayer identification number, or employer identification number); or  Non-U.S. Person - one or more of the following: A taxpayer identification number; Passport number and country of issuance; Alien identification card number; Number and country of issuance of any other government issued document evidencing nationality or residence and bearing a photograph or similar safeguard. [A copy of the Primary Identification documents (passport, ID) must be obtained and scanned / copied for Imaging] Note: In the case of an elderly customer, Minor, and Law enforcement that cannot produce the required documents, refer to the listing CIP Matrix for a list of identifications that may be produced for verification purposes. Note: If the customer's identification does not include a local or current address, obtain and document a secondary Identification form with a local or current address. Refer to the CIP Matrix for a listing of Secondary ID Verifying Account Opening Documentation (Documentary and non-Documentary verification.) • The identifying information must be verified before the account is opened. Inspect the documentation and compare the photograph and the description on the ID with the person presenting the document. • In general, two forms of identification are required to open an account. This includes a primary and a secondary piece of identification or a non-documentary verification. The Bank's required standard identification, documents and non-documentary verification are listed in the CIP Matrix. • In addition, signatures should be compared from the identification to the signature provided by the customer on the Bank's loan application or signature cards. [If there is any doubt on the identity of the customer, you may send thank-you letters or call customers after account opening to ensure that you have correct data in your files. For example, for an individual you may wish to verify the telephone number using a reverse directory to ensure the information you received is accurate.] • If the bank is not able to verify the true identity of the customer through documents, the account must be closed. This action should take no longer than 10 business days from the start of the application or opening of the account. • Awaiting TIN or SSN — For deposit accounts, have the customer certify his/her social security number (SSN) or taxpayer identification number (TIN) on IRS Form W9 or the signature card. If the customer does so, this procedure is complete. If the customer has applied for, but not received, TIN or SSN, the account but be postponed until the customer can provide all required documentation.

For Training Purposes Only

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